Gujarat High Court Allows Pfizer's Additional Claims Worth ₹15 Crore Under Central Sales Tax Act, Sets Aside VAT Tribunal Order
The Gujarat High Court has allowed writ petition by Pfizer, a pharmaceutical major against the Value Added Tax (VAT) Tribunal order that expressly barred the consideration of any additional Form-F. In a judgment dated November 20, 2025, the Division Bench comprising Justice Pranav Trivedi and Justice A.S. Supehia noted the 11-year pendency in litigation in relation to production of...
The Gujarat High Court has allowed writ petition by Pfizer, a pharmaceutical major against the Value Added Tax (VAT) Tribunal order that expressly barred the consideration of any additional Form-F.
In a judgment dated November 20, 2025, the Division Bench comprising Justice Pranav Trivedi and Justice A.S. Supehia noted the 11-year pendency in litigation in relation to production of Form-F under the Central Sales Tax Act, 1956. In this vein, the High Court deliberated on piecemeal production of Form-F for interstate branch transfers. It held the additional Form-F valued at ₹16 crores in terms of VAT Tribunal order as maintainable since Petitioner stated that future claims would be waived by it.
In 2017, Petitioner was assessed for the assessment year 2012-13 which indicated gross turnover of ₹135 crores approximately. This included local sales of ₹41,78,40,249 and inter-State branch transfer of ₹93,80,90,322. Petitioner secured Form-F for about ₹49 crores for inter-state branch transfers but could not secure Form-F for the remaining ₹44 crores.
During proceedings before the First Appellate Authority, Petitioner secured additional Form-F worth ₹17.65 crore. However, the VAT Tribunal held the additional Form-F as not maintainable and on the remaining amount tax, interest and penalty came to be levied
Hence, by way of the present writ petition Pfizer prayed for quashing of VAT Tribunal order and consideration of additional Form-F as valid.
As opposed to the VAT Tribunal's express bar on additional Form-F, Petitioner recalling how Form-F validated the occurrence of stock transfers for the purposes of exemption, submitted that the production of Form-F still pending would not be contested in the future.
The High Court upheld Petitioner's eligibility for exemption under the Central Sales Tax Act, 1956. Further, the High Court also noted Petitioner's assurance that the claim of the amount of Form-F which were not produced would not be contested by the it in future.
Accordingly, the High Court directed the Authorities to consider additional Form-F produced by the Petitioner and as verified by the Authorities.
Case Detail: PFIZER Limited vs. State of Gujarat & Ors.
Case No.: Special Civil Application No. 143 of 2025
For Petitioner: Senior Advocate Mihir Joshi with Advocate Dhaval Shah
For Respondent: Assistant Government Pleader Pooja Ashar